
Davis Polk's Tax Controversy Group represents taxpayers at every stage of governmental interaction, from obtaining advance pricing agreements and private letter rulings to civil trials and criminal prosecutions, and we have prevailed in many contested tax matters. We have represented major U.S. and international corporations and financial institutions in the U.S. Court of Claims and the U.S. Tax Court. We have obtained reversals of tax fraud convictions on important constitutional grounds, and we prevailed before the New York State Tax Commission and the Court of Appeals in matters of state taxation.